(arguably including stun grenades) and some common types of riot control agents are included, the WA lists do not cover certain widely employed RCAs such as OC, pepper sprays or synthetic versions such as PAVA. Similarly, neither electric shock weapons nor many newer types of less lethal system such as optical dazzlers, acoustic devices or directed energy weapons are currently covered by the WA lists.lxviii Unfortunately the regulatory situation outside of the WA Member States is even worse. Many States where new production of less lethal munitions and equipment is being set up have weak or non-existent exports controls on such equipment, and export goods with little or no transparency at all. This almost complete lack of control and transparency on the trade and transfer of less lethal weapons and devices means that States with poor human rights records, including those where such equipment may be misused for torture or other ill-treatment, can continue to obtain such equipment and continue to misuse it. However, there are indications that a growing number of States recognise their international obligations to effectively regulate the trade of certain less lethal weapons and associated law enforcement equipment, especially if such equipment can be readily (mis)used for torture and other ill-treatment. For example at the regional level, in May 2005 the EU adopted Council Regulation (EC) No. 1236/2005 concerning trade in goods which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment. The EU ‘Torture Regulation’, which came into force in May 2006, filled a major gap in human-rightsbased export controls, introducing unprecedented trade controls that are binding on all EU Member States on a range of security equipment – including certain electric shock weapons, RCAs and kinetic impact weapons. It has since been progressively strengthened with the latest set of amendments extending coverage to bans on promotion, brokering and transit of torture and death penalty goods across the EU, among other provisions.lxix At the international level a major advance occured on 18 September 2017 with the launch of Alliance for Torture Free Trade. To date, over 60 states from all regions of the world have signed its Political Declaration to act together “to further prevent, restrict and end trade in goods intended for use in torture or capital punishment”; and to adopt legislation and efficient enforcement systems for the restriction and elimination of trade in such goods.lxx In September 2018 the Global Alliance Member States committed themselves to working to establish a UN process to explore “the feasibility and possible scope of a range of options, including a legally binding instrument, to establish common international standards for the import, export and transfer of goods used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment”lxxi States should establish effective national measures to regulate the trade in less lethal weapons and associated law enforcement equipment. Such measures should:  Prohibit the export, import, transit, or trans-shipment of any less lethal weapons and equipment that has no practical use in law enforcement other than for the purpose of torture and other cruel, inhuman or degrading treatment or punishment; or where its use in practice has revealed a substantial risk of unwarranted injury.  Strictly regulate the export, import, transit, or trans-shipment to law enforcement agencies of less lethal weapons and equipment that can be used legitimately in a manner consistent with international human rights standards for law enforcement, but nevertheless could also be misused to conduct or

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